Prepare a report – Government institutions

Process overview

Reporting government institutions must complete the following steps of the reporting process ahead of the May 31 deadline:

1. Prepare a report

Reporting government institutions must develop a report that meets all of the requirements of the Act. Government institutions are expected to consult internally and gather the information needed to complete their report. Refer to the guidance for government institutions for more information.

2. Complete online questionnaire

Once the report is complete, in both Canadian official languages, government institutions must complete the online questionnaire in the Canadian official language of their choice by May 31. The questionnaire includes a series of open- and closed-ended questions that address each of the requirements under the Act.

Government institutions must ensure the information provided in the questionnaire is consistent with the information provided in their report.

If a government institution is unable to complete the online questionnaire and needs to submit their answers directly via email, contact: SupplyChainsActInquiries-LoiChainesApprovisionnementEnquetes@ps-sp.gc.ca.

3. Upload completed report

At the end of the questionnaire, government institutions must upload their English and French reports as separate PDF files before they select “submit.”

Government institutions will receive confirmation acknowledging their submission.

4. Publish report to government institution’s website

Government institutions must publish their report on a prominent place on their website.

Submitted reports will also be made publicly available in a searchable online catalogue. The PDF reports and select identifying information submitted through the online questionnaire will be the only information published on the Public Safety Canada website.

The May 31 deadline only applies to government institutions’ requirement to submit their report and questionnaire; government institutions must publish their reports on their respective websites following their submissions to Public Safety Canada.

Report requirements

A report must meet all of the following requirements:

Include information addressing each of the requirements in subsections 6(1) and 6(2) of the Act
Is a PDF file that does not exceed 100MB in size (government institutions must upload two separate reports, one in each Canadian official language, and the size limit applies to each of the reports)

The questionnaire may be used as a resource for developing reports. The questionnaire is designed to collect information necessary to satisfy the requirements of the Act. More information and supplementary content (e.g. charts, graphs) may be included in the government institution’s report at their discretion. Government institutions are responsible for ensuring that their published reports meet the requirements outlined in the Policy on Communications and Federal Identity and the federal Procedures for Publishing.

Completing the online questionnaire is mandatory. Further details on report preparation and contents are available in the guidance.

Mandatory information

Effective January 1, 2024, government institutions must, on or before May 31 of each year, submit a report to the Minister of Public Safety on:

The steps the government institution has taken during its previous financial year to prevent and reduce the risk that forced labour or child labour is used at any step of the production of goods produced, purchased or distributed by the government institution
Its structure, activities and supply chains
Its policies and due diligence processes in relation to forced labour and child labour
The parts of its activities and supply chains that carry a risk of forced labour or child labour being used and the steps it has taken to assess and manage that risk
Any measures taken to remediate any forced labour or child labour
Any measures taken to remediate the loss of income to the most vulnerable families that results from any measure taken to eliminate the use of forced labour or child labour in its activities and supply chains
The training provided to employees on forced labour and child labour
How the government institution assesses its effectiveness in ensuring that forced labour and child labour are not being used in its activities and supply chains

Questionnaire

Completing the online questionnaire is mandatory. The questionnaire is designed to collect information necessary to satisfy the requirements of the Act, and includes mandatory and optional questions. Some mandatory questions collect identifying information about the government institution, such as the financial year for which the report was completed. Other mandatory questions collect information needed to comply with each of the Act’s reporting requirements. These are followed by optional open-ended questions (1500-character limit) that allow government institutions to elaborate on their responses to the mandatory closed-ended questions and to provide additional information, if desired.

Government institutions are strongly encouraged to fill out the optional open-ended questions in the questionnaire. Collecting this information over time is expected to improve government institutions’ capacity to identify, prevent, reduce and address forced labour and child labour risks. By providing this information, government institutions can demonstrate leadership and responsibility and provide the level of transparency that members of the public are looking for. Though it is not required, government institutions can use the exact same information and structure provided through the questionnaire to prepare their report. Government institutions may complete the online questionnaire in either official language.

Guidance for government institutions

Guidance on preparing a report

Official language requirements

Government institutions must ensure to have their reports available in the two Canadian official languages, as per the linguistic obligations relating to communications with and services to the public (Part IV) and language of work (Part V) under the Official Languages Act.

Format and length

The report must include information addressing each of the requirements in subsections 6(1) and 6(2) of the Act. Government institutions may use the questionnaire as a template, but it is not required.

The report must be submitted to Public Safety Canada in PDF format. Government institutions will only be able to upload reports that do not exceed 100MB. It is recommended, but not required, that the report does not exceed 10 pages in length.

Reporting government institutions are responsible for determining their own approval process and securing the required approvals before their reports are submitted to Public Safety Canada.

Submitting a revised report

Government institutions may provide a revised version of the report at any time within one year of the applicable reporting deadline. Submitting a revised report allows government institutions to make the necessary changes to their report should it be found to not meet the minimum requirements of the Act. It also allows government institutions to supplement or update the information provided should the government institutions’ situation change or should any new information become available.

To submit a revised report, government institutions must complete the online questionnaire a second time, indicating the date of revision and including a description of the changes made to the original report. The revised report must be published in a prominent place on the government institutions’ website. Note that the previous version of the questionnaire responses will be deleted and cannot be recovered.

Publishing a report on the government institution’s website

All government institutions are required to publish their report in a prominent place on their website. Government institutions may use their discretion in determining the appropriate place to publish the report, but it must be available to members of the public. While the report must be submitted to Public Safety Canada in PDF format, Public Safety Canada is not responsible for the publication of reports on government institutions’ websites. Government institutions must ensure that their published reports meet the requirements outlined in the Policy on Communications and Federal Identity and the federal Procedures for Publishing.

Financial reporting year

All reports must reference the activities undertaken during the government institution’s previous financial year. A report should cover the activities of the financial year that ends no later than the reporting deadline. For example, if a government institution’s financial year starts on April 1 and ends on March 31 of the following calendar year, then a report submitted on May 31, 2024 would cover activities undertaken from April 1, 2023 to March 31, 2024.

Guidance on the application of the Act

The Act defines government institution as having the same meaning in section 3 of the Access to Information Act (AIA):

any department or ministry of state of the Government of Canada, or any body or office, listed in Schedule I, and
any parent Crown corporation, and any wholly-owned subsidiary of such a corporation, within the meaning of section 83 of the Financial Administration Act (FAA).

The head of the government institution, as per section 3 of the AIA, is defined as:

in the case of a department or ministry of state, the member of the King’s Privy Council for Canada who presides over the department or ministry, or
in any other case, either the person designated under subsection 3.2(2) to be the head of the institution for the purposes of this Act or, if no such person is designated, the chief executive officer of the institution, whatever their title.

Reporting obligations apply to government institutions engaged in producing, purchasing or distributing goods in Canada or elsewhere.

Provincial and municipal governmental institutions are not subject to these reporting requirements. However, some provincial agent Crown corporations may fall under the definition of “entity." It is their responsibility to determine whether they are a reporting entity under the Act. Learn more about reporting requirements for entities.

Crown corporations

While Crown corporations could in some instances fall under the definition of “entity” or “government institution,” the duty of government institutions to report is ultimately enforced by the relevant Minister’s responsibility to Parliament, as per section 88 of the FAA. As such, federal Crown corporations that fall under the definition of “government institution” should complete a report using the guidance and reporting process specifically designed for government institutions, with their legal requirements provided under Part 1 of the Act.

Meaning of producing, purchasing and distributing goods

The Act specifies that the production of goods includes the manufacturing, growing, extracting and processing of goods. The terms purchasing and distributing are not explicitly defined in the Act. However, the terms as they are used in the Act are not intended to capture services that solely support the production, purchase or distribution of goods. These include, for example, marketing, administrative services, financial services and software services. Government institutions should apply the ordinary sense of these words to judge whether they are engaged in any of these activities.

For the purposes of the Act, goods refers to goods that are the subject of trade and commerce, understood in the ordinary sense of the word.

There is no prescribed threshold for the minimum value of goods that a government institution must produce, purchase or distribute in order for the Act to apply. However, the terms as they are used in the Act should be understood as excluding very minor dealings.

Guidance on report contents

A complete report will contain responses that are consistent with the information provided in the questionnaire.

There is no prescribed level of detail required for the responses. Government institutions should use discretion in determining the appropriate level of detail proportionate to their size and risk profile, respecting the specified size requirements for the report.

Government institutions may include visual aids so long as they follow the requirements outlined in the guidance.

Government institutions may provide additional information to supplement responses, if desired, including links to relevant websites and publicly available documents. For example, government institutions may provide links to:

An action plan
A policy
A code of conduct
The report from a risk-assessment or supply chain mapping exercise
The results of an internal or external review or audit
A public supplier list
Any relevant public disclosures or statements

In the first year of reporting, government institutions may not have measures to report on for some of the requirements of the Act. Government institutions may indicate in their report that no measures have been taken to prevent and reduce the risk of forced labour or child labour in their activities and supply chains, or that action plans have not yet been implemented, if that is the case. Doing so is sufficient to meet the government institution’s legal obligations.

The Government of Canada recognizes that government institutions may be taking a range of actions related to human rights due diligence, environmental, social and governance (ESG) initiatives and other aspects of responsible business conduct (RBC) that are not specifically or exclusively focused on forced labour or child labour. Government institutions can include a description of these actions as they relate to purposes of the Act in the space provided for additional information. Government institutions can also connect the description of their actions in the present reporting year to foundational work undertaken in previous years.

The report should focus on actions taken during the previous financial reporting year, with the recognition that some actions may span multiple years or lack a concrete start and end point. However, government institutions are encouraged to note where they are in the process of developing their response to forced labour and child labour, even if the measures have not yet been fully implemented.

The Act does not require government institutions to disclose sensitive information that would create legal risk or compromise the privacy of any persons. Government institutions are also not required to report on specific cases or allegations of forced labour or child labour. The description of the forced labour and child labour risks identified and the description of any remediation measures taken need not reference specific instances, persons or groups.

Answering all the mandatory questions included in the questionnaire, posting the report in both official languages on the government institution’s website and submitting the report in both Canadian official languages to Public Safety Canada is sufficient to meet the requirements of the Act.

Components of the report

The questionnaire asks for the following identifying information about the government institution and about the report:

Government institution’s name
Financial reporting year
Identification of a revised report

If the report is for a federal Crown corporation or a subsidiary of a federal Crown corporation, the questionnaire also requires the following identifying information:

Sector/industry
Location

Government institutions must address each of the requirements included in section 6 of the Act in their annual report. This includes:

A description of the steps taken to prevent and reduce risks of forced labour and child labour, as per subsection 6(1)
Supplementary information addressing each of the seven requirements in subsection 6(2)

Government institutions are encouraged to refer to the list of resources for further guidance as they prepare their report.

Subsection 6(1) provides that a government institution must describe the steps it has taken during its previous financial year to prevent and reduce the risk that forced labour or child labour is used at any step of the production of goods produced, purchased or distributed by the government institution.

As per subsection 6(2), a government institution must also provide information on each of the following:

Its structure, activities and supply chains
Its policies and due diligence processes in relation to forced labour and child labour
The parts of its activities and supply chains that carry a risk of forced labour or child labour being used and the steps it has taken to assess and manage that risk
Any measures taken to remediate any forced labour or child labour
Any measures taken to remediate the loss of income to the most vulnerable families that results from any measure taken to eliminate the use of forced labour or child labour in its activities and supply chains
The training provided to employees on forced labour and child labour
How the government institution assesses its effectiveness in ensuring that forced labour and child labour are not being used in its activities and supply chains

Steps to prevent and reduce risks of forced labour and child labour

The questionnaire provides examples of measures that government institutions may have taken to prevent and reduce risks of forced labour and child labour. This list is not exhaustive, and government institutions are encouraged to name any other steps they have taken in the open-text field. Government institutions are also encouraged to provide additional information describing their actions. Examples of additional information include:

Whether the actions were applied broadly or to specific parts of the government institution’s activities (e.g., purchasing)
Which issues the actions aimed to address (e.g., whether the action addressed forced labour or child labour)
Which groups the actions were directed towards (e.g., which supply chain partners or stakeholders the government institution engaged with)
Details of the actions taken (e.g., which policies and processes were implemented, how they were implemented and for what purpose)

There may be overlap between the steps government institutions identify in this section and responses to subsequent questions, such as the questions on due diligence and on training for employees. This is expected and acceptable.

A description of the steps taken is intended to identify risks associated to the use of forced labour and child labour, while the rest of the questions gather supplementary information on specific aspects of that response.

Requirement (a) – Structure, activities and supply chains

Structure refers to the government institution’s legal and organizational form. When reporting on structure, government institutions may include the following details:

Legal structure
Organizational structure (i.e., departmentation, chain of command, etc.)
Organizational mandate or role
Number of employees, both in Canada and outside Canada

Activities include all pursuits undertaken by the government institution in relation to the production, purchase or distribution of goods by the government institution.

When reporting on activities, government institutions may include information on:

Production, manufacturing, growing, extracting, processing, purchasing or distribution of goods, both in Canada and outside Canada, including the kinds and volumes of goods produced, manufactured, grown, extracted, processed, purchased or distributed
Locations of operation (countries or regions)

The supply chain includes suppliers of goods and services that contribute to the production of goods produced, purchased or distributed by the government institution, from sourcing the raw materials to the final product. It includes direct and indirect suppliers and service providers, both in Canada and outside Canada. A government institution’s supply chain does not include the end users or customers who purchase its products or services.

When describing their supply chains, government institutions should aim to describe the main types of goods the institution produces, purchases or distributes. Answers should also identify to the greatest extent possible the source countries or regions of origin of each of the goods and services used at each stage of the supply chain, if known.

Government institutions should aim to provide a complete overview of their structure, activities and supply chains, meaning that they should not omit information about aspects of their structure, activities and supply chains that they have judged carry no risk of forced labour or child labour.

The lists of examples given above are not exhaustive, and government institutions are encouraged to provide additional information, as appropriate.

Requirement (b) – Policies and due diligence processes

Due diligence is a process to identify and respond to the real and potential adverse impacts of activities throughout the supply chain. The OECD Due Diligence Guidance for Responsible Business Conduct provides that the due diligence process and its support measures involve the following steps:

Embedding responsible business conduct (RBC) into policies and management systems
Identifying and assessing adverse impacts in operations, supply chains and business relationships
Ceasing, preventing or mitigating adverse impacts
Tracking implementation and results
Communicating how impacts are addressed
Providing for or cooperating in remediation when appropriate.

The meaning of due diligence as it applies to government institutions may be interpreted to align with international human rights law obligations, as outlined in the United Nations Guiding Principles on Business and Human Rights.

The Guiding Principles specify that States have a duty to protect against human rights abuse within their territory and/or jurisdiction by third-parties, including business enterprises. The duty to protect includes promoting respect for human rights by business enterprises with which the state conducts commercial transactions, including via procurement.

For more information on the meaning of due diligence and the ways in which a government institution can implement due diligence practices, please see the list of additional resources.

In a government institution ’s report, they may choose to describe how their organization’s policies and due diligence processes on forced labour and child labour relate to its environmental, social and governance (ESG) initiatives or to a broader organizational Responsible Business Conduct (RBC) strategy, policies or mandate.

Requirement (c) – Forced labour and child labour risks

Government institutions must identify parts of their activities and supply chains that carry a risk that forced labour or child labour is being used either in their own activities or those of their direct or indirect suppliers. Identifying parts of an organization’s activities and supply chains that carry a risk does not require indicating that forced labour or child labour was or is actually being used. Rather, government institutions are asked to show that they have considered the ways in which their activities and supply chains could potentially cause, contribute to or be directly or indirectly linked to actual or potential risk that forced labour or child labour is used by them or in their supply chains.

No sectors or industries involving the production, purchasing or distribution of goods are assumed to be entirely free of forced labour and child labour risks. The purpose of reporting is not to certify that a government institution is “risk-free,” but rather to demonstrate that the government institution has taken steps to identify and address risks. The reporting exercise is intended to encourage transparency, not to penalize government institutions for having identified risks in their activities and supply chains.

Government institutions should not disclose commercially sensitive information. Do not report on specific cases or allegations of forced labour or child labour in a manner that could create legal or privacy concerns.

The questionnaire, which may be used as a guide for developing the report, allows government institutions to identify general aspects of their activities and supply chains that carry a risk of forced labour and child labour, as well as the sectors and industries to which those risks relate. Government institutions are encouraged to provide additional information in their questionnaires and annual reports. For example, government institutions may specify that they have identified risks related to a particular sector, industry, country or region; the production of a particular product; or a particular step in the supply chain.

Government institutions may choose to volunteer information about instances of forced labour or child labour that have been identified, but are not required to do so. If this information is included, government institutions should ensure that their report does not compromise any individual’s privacy. For example, government institutions may describe their response to forced labour or child labour identified in a particular part of their activities or supply chains using an anonymized case study.

Additionally, the questionnaire allows government institutions to describe the steps that they have taken to assess and manage the forced labour and child labour risks identified. In other words, government institutions should explain how they have identified risks (i.e., mapping supply chains, conducting a risk assessment, etc.) and how they have dealt with the risks identified. Government institutions may use the examples provided in the questionnaire in their annual reports, or provide a general description of how they assess and manage risks.

Requirement (d) – Remediation measures

Remediation and remedy refer to both the processes of providing remedy for an adverse impact and to the substantive outcomes (i.e., remedy) that can counteract, or “make good,” the adverse impact. In the case of business and human rights, which includes forced labour and child labour, remedies provided may take a range of forms, the aim of which will be to counteract or address any human rights harms that have occurred.

Appropriate remedies vary depending on the circumstances.

For more information on the meaning of remediation, please see the United Nations Guiding Principles on Business and Human Rights and the list of additional resources.

The questionnaire includes a list of possible remediation measures. This list is not exhaustive, and government institutions are encouraged to provide additional information.

As with reporting on risks of forced labour and child labour, the purpose of requiring government institutions to describe the measures they have taken to remediate any forced labour or child labour is to encourage transparency.

Government institutions should not disclose commercially sensitive information or report on specific cases or allegations of forced labour or child labour in a manner that could create legal or privacy concerns.

If government institutions have assessed that their activities and supply chains do not carry a risk of forced labour or child labour being used, and the question of remediation is considered not applicable, then stating this in their report would be sufficient to address this requirement.

Alternatively, government institutions may indicate that no measures have been taken to remediate forced labour or child labour in the organization’s activities and supply chains, if that is the case.

Requirement (e) – Remediation of loss of income

Efforts to prevent and reduce the risk of forced labour and child labour can have the unintended consequence of contributing to a loss of income for the most vulnerable families. This requirement refers to any measures taken to remediate the loss of income to the most vulnerable families that results from any measure taken to eliminate the use of forced labour or child labour in the government institution’s activities and supply chains.

As with the requirement to report on remediation measures, if government institutions have judged that vulnerable families have not experienced loss of income as a result of steps taken to eliminate forced labour or child labour risks, or if no measures have been taken in this area, then stating this in the report is sufficient to address this requirement.

Requirement (f) – Training

Training on forced labour and child labour may take a range of forms, from formal training courses to awareness-raising activities. When reporting on the training that government institutions may provide to employees, they may choose to provide the following details:

Whether the training is mandatory or optional
Whether the training is government institution-wide or only covers employees in specific areas of the government institution
Which groups or levels of employees receive the training (e.g., whether the training covers senior management/executive-level staff)
The content of the training, including whether it covers forced labour, child labour or both
How the training was developed, including whether it was developed internally or by an external organization
The length of the training
Any mode(s) of assessment included in the training
How many employees have received or will receive the training

This list of examples is not exhaustive, and government institutions are encouraged to provide additional information, as appropriate.

In addition to describing the training provided to a government institution’s direct employees, government institutions may choose to describe any training or awareness materials provided to partners or suppliers, if applicable.

Requirement (g) – Assessing effectiveness

The questionnaire includes a list of examples of steps government institutions may take to assess their effectiveness in ensuring that forced labour and child labour are not being used in their activities and supply chains. This list is not exhaustive, and government institutions are encouraged to provide additional information.

Government institutions are required to report on how they assess their effectiveness, not to give the results of that assessment. In other words, government institutions should describe the policies, processes and other actions they have implemented to measure and track their success in preventing and reducing risks of forced labour and child labour in their activities and supply chains.

Alternately, government institutions may indicate that no actions have been taken to assess their effectiveness in preventing and reducing risks of forced labour and child labour in their activities and supply chains. Stating this in a report is sufficient to address this requirement.

Date modified:: 2024-03-13

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